Indeed, an old BIA decision held that institutionalization in a state mental hospital could serve as the basis for a “conviction” even though the individual there was not ordered into a penal institution. Matter of V, 7 I. & N. Dec. 242 (BIA 1956). More recently, the BIA held that imposition of court costs constituted a “penalty” for INA § 101(a)(48)(A)(ii) purposes.